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ATTACHMENT 4.3-1A 
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ATTACHMENT 4.3-1B 

NOTICE

NOTICE
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ATTACHMENT 4.3-1C 
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ATTACHMENT 4.3-1D 
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ATTACHMENT 4.3-1E 
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Finding 4.3-2: Use of the 1,050 MAC-hours Per Year as a Default Value for a Bounding 

Intake of Thorium is Inappropriate

With the noted changes regarding NIOSH’s intended approach for estimating thorium intakes, 

SC&A is uncertain whether NIOSH still intends to employ the default and bounding intake of 

1,050 MAC-hours per year, as described in Section 5.2.3 of ORAUT-TKBS-0017-5. In the 

event of its use in dose reconstruction, SC&A firmly believes that the 1,050 MAC-hours per year 

is clearly not a “. . . default intake rate [that] applies to the most exposed craft personnel (e.g., 

chemical operators, process maintenance personnel, safety personnel, and first-line 

supervision/foremen) . . .” 

A review of air sampling data clearly shows concentrations in the hundreds and even tens of 

thousands of MACs/NCG. For example, Attachments 4.3-1A, 4.3-1B, and 4.3-1D enclosed 

above under Finding 4.3-1 identify maximum air concentrations of 1,262 NCG (or 1,803 MAC), 

8,571 MAC, and 1,260 MAC, respectively. Exposures to these air concentrations would exceed 

the default value of 1,050 MAC-hours per year in as little as eight minutes. 

Finding 4.3-3: Limitations Associated with the Use of Job Task(s)/Job Location(s) for the 

Assignment of Intakes that are based on Air Sampling Data

The feasibility of assigning time-integrated air concentrations and/or lung burdens is severely 

limited for a sizeable fraction of FMPC workers. Numerous FMPC documents make reference 

to high-exposure environments/job tasks that were performed by members of the Project Labor 

Pool, roving maintenance crew, and roving operators. 

Attachments 4.3-3A, 4.3-3B, 4.3-3C, and 4.3-3D verify the existence of such workers and their 

high exposure potential. The difficulty of tracking these and other individuals on the basis of 

“records” was fully recognized by FMPC Health and Safety personnel as opined in 

Attachments 4.3-3C and 4.3-3E and summarized below: 

• From Attachment 4.3-3C in which the Director of FMPC’s Health and Safety Division 

stated the following in 1953: 

This brief case study also afforded an opportunity to realize two major 

problems confronting this division. First, we often do not have a complete 

work history, especially of roving maintenance men, such as [Name]. 

However, there are men in other departments who are working in other areas 

or have been transferred, and our first knowledge at least in the Medical 

Department of their job locations is when they present themselves for medical 

care. The man then reveals that he is working in a different area from the 

one noted on his medical records. I cannot argue with anyone who says our 

records are not up to date, but often we are not notified of transfer to specific 

areas and we do not have the personnel to scout each man. [Emphasis 

added.] 
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• From Attachment 4.3-3E in which the Director of FMPC’s Health and Safety Division 

restated these concerns in 1963: 

Another serious problem in determining internal exposure is the difficulty in 

obtaining good work records, which show how long an individual has worked 

in various jobs. Five of the jobs in the table are performed by employees with 

the job classification of “chemical operator.” The other two are classified 

“chemical operator helper” and “laborer.” We have records which tell us to 

which plants a person is assigned and in which job classification he worked 

however, these records do not tell use the specific job operation he 

performed. [Emphasis added.] 

SC&A concludes that, for a large fraction of workers, records that may define a claimant’s job 

description/job location are unlikely to be accurate, complete, or sufficiently detailed to be of use 

in dose reconstruction. (SC&A notes that, while Attachment 4.3-3C and 4.3-3E pertain to 

uranium workers, it is reasonable to assume that this problem equally applies to thorium 

workers.) 
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ATTACHMENT 4.3-3A 
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ATTACHMENT 4.3-3B 
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ATTACHMENT 4.3-3C 
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Attachment 4.3-3C (Continued) 
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ATTACHMENT 4.3-3D 

s 
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ATTACHMENT 4.3-3E 
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Attachment 4.3-3E (Continued) 
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Finding 4.3-4: The Inability to Account for Internal Exposures Associated with 

Radiological Thorium Incidents

Section 5.3.5 of NIOSH’s SEC Evaluation Report acknowledges the fact that: 

. . . fires and small explosions resulted from working with uranium and thorium 

metal, especially when molten metal, stored un-oxidized metal turning or scraps, 

or phosphorus and magnesium compounds were involved. Interviews with former 

FMPC workers, including fork truck operators tasked with moving burning drums 

of uranium, reinforced that small fires and explosions occurred frequently, 

perhaps even daily at times. The majority of these incidents resulted in only local 

contamination. Other incidents mentioned by interviewees included ventilation 

exhaust system filter bag breaches, high dust levels from certain operations, and 

spills from drums of uranium ore. [Emphasis added.] 

Nevertheless, the ER dismisses these incidents and concludes with the following statement: 

There were two serious incidents that had the potential to result in significant 

personnel exposure: a thorium blender incident and a uranium hexafluoride gas 

release.

While SC&A concurs with the high frequency of incidents, SC&A rejects NIOSH’s conclusion 

that only two incidents had significant potential for worker exposure. 

Our review of FMPC’s historical memoranda and numerous reports contained in the SEC 

Petition-00046 verifies the ubiquitous and serious nature of these radiological incidents (see 

Attachments 4.3-4A and 4.3-4B). Specifically of concern are thorium incidents that cannot be 

quantified by means of routine spot air sampling data. 

Apparently, of interest to FMPC administrative personnel was the reduction of thorium 

compounds to thorium metal that was pioneered at the Ames Laboratory, as well as the need to 

respond to the pyrophoric/explosive nature of thorium materials (see Attachment 4.3-4C). 

The inability to account for exposures associated with thorium incidents is due to the following: 

(1) Breathing zone air sampling at specific work locations was episodic at best

(2) When performed, air sampling was limited to sampling times as brief as 1 minute per 

sample

(3) With rare exception, air sampling data that assessed radiological incidents were never 

documented and are therefore unavailable

(4) Activity levels associated with fires, explosions, spills, etc. can raise air concentrations by 

several orders of magnitude
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Attachment 4.3-4D contains isolated study data that document the dramatic rise in general air

samples associated with derby fires. In the absence of a derby fire(s), the average “background” 

air concentration was recorded at 2.1 MAC; with one derby fire, the average general air

concentration rose to 458 MAC, which is a 218-fold increase over the background level. The 

potential for even higher air levels must be expected if breathing zone air samples had been 

taken. 

In behalf of Finding 4.3-4, SC&A concludes the following: 

(1) Thorium incidents with potentially high internal exposure occurred frequently and likely 

affected a large pool of workers 

(2) The failure to document and assess these incidents preclude both the identity of affected 

workers or the ability to quantify/bound internal thorium exposure 
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ATTACHMENT 4.3-4A 
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ATTACHMENT 4.3-4B 
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ATTACHMENT 4.3-4C 
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Attachment 4.3-4C (Continued)